Site sends data overseas but the privacy policy doesn't disclose it
This check looks at whether the site loads third-party services, such as Google or Meta, that typically send Australian visitors' personal information to servers outside Australia, and then checks whether the privacy policy mentions this. On this site, overseas-hosted services were found loading, but the crawled privacy policy text does not appear to mention any overseas or cross-border data transfer. Australian Privacy Principle 8 (APP 8) requires a privacy policy to disclose when personal information is sent to recipients overseas. A missing overseas-disclosure clause is a concrete, easily fixable compliance gap, and it's the kind of finding that surfaces in OAIC (Office of the Australian Information Commissioner) complaints and in enterprise procurement reviews, exactly where an agency's SMB clients tend to get caught out. Your privacy lawyer should add a clause naming which overseas services are used, for example US-based providers like Google and Meta, and where data may be sent as a result. Most privacy policy templates already include placeholder wording for this that just needs the actual vendor list filled in, so it's typically about an hour or two of drafting.
Why this matters
Australian Privacy Principle 8 (APP 8) requires a privacy policy to disclose when personal information is sent to recipients overseas. A missing overseas-disclosure clause is a concrete, easily fixable compliance gap, and it's the kind of finding that surfaces in OAIC (Office of the Australian Information Commissioner) complaints and in enterprise procurement reviews, exactly where an agency's SMB clients tend to get caught out.
How to fix it
Your privacy lawyer should add a clause naming which overseas services are used, for example US-based providers like Google and Meta, and where data may be sent as a result. Most privacy policy templates already include placeholder wording for this that just needs the actual vendor list filled in, so it's typically about an hour or two of drafting.